REGAFFAIRS AI
Guide · 2026-10-23 · 5 min

Is there an OSHA hazardous chemical list? The lists OSHA keeps

OSHA has no single hazardous chemical list. HazCom status comes from classification. These are the lists OSHA keeps: Table Z-1, Subpart Z, carcinogens.

Is there an OSHA hazardous chemical list?

There is no single OSHA hazardous chemical list under HazCom. In OSHA's words, "OSHA does not maintain a list of chemicals covered under the HCS." Under 29 CFR 1910.1200, hazard classification determines coverage, not membership on a master list.

OSHA does keep narrower lists for air contaminants, substance-specific standards and process safety. Being on one, or on none of them, does not by itself settle HazCom status.

What counts as a hazardous chemical under HazCom

1910.1200(c) defines a hazardous chemical as "any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, or hazard not otherwise classified." The standard covers a chemical employees may be exposed to "under normal conditions of use or in a foreseeable emergency."

Under 1910.1200(d), manufacturers and importers classify chemicals they produce or import. Health hazards are classified under Appendix A, and physical hazards under Appendix B. There is no requirement to test the chemical. Employers who don't manufacture or import can rely on the supplier's classification.

A PEL or an ACGIH TLV does not, by itself, make a chemical hazardous under the current text. A substance can still be hazardous if it has no OSHA limit. Appendix D requires the OSHA permissible exposure limit (PEL) and the ACGIH threshold limit value (TLV) in SDS Section 8.

The lists OSHA does keep

ListWhereWhat it does
Tables Z-1, Z-2, Z-329 CFR 1910.1000Exposure limits for listed air contaminants
Substance-specific standardsSubpart ZControls for named regulated chemicals
Carcinogen standardsCarcinogen standards, including 1910.1003Carcinogens named in specific standards
Highly hazardous chemicals1910.119 Appendix APSM threshold quantities

Tables Z-1, Z-2 and Z-3

1910.1000 limits an employee's exposure to any substance listed in these tables. Table Z-1 has several hundred rows, with 8-hour time-weighted average (TWA) limits and ceilings. Some rows point to another standard. The benzene entry says "see 1910.1028".

Table Z-2 sets a TWA, an acceptable ceiling and an acceptable maximum peak for 21 entries, including formaldehyde, toluene and trichloroethylene. Table Z-3 covers mineral dusts, including silica, Portland cement, graphite and coal dust.

But these tables are exposure limits, not a hazard inventory. OSHA's Annotated PEL Tables recognize that many PELs are "outdated and inadequate." Most were issued shortly after the OSH Act in 1970. The annotated tables show Cal/OSHA PELs, NIOSH recommended exposure limits and ACGIH TLVs beside the OSHA PEL.

Subpart Z substance-specific standards

Subpart Z of Part 1910 is titled "Toxic and Hazardous Substances." Its substance-specific standards cover regulated chemicals such as asbestos, lead and benzene. Duties can go beyond a PEL to exposure monitoring, a regulated area or medical surveillance. Subpart Z also holds HazCom and the laboratory standard.

The OSHA carcinogen list

OSHA's carcinogens page gives no master list. Carcinogens "are addressed in specific OSHA standards." The carcinogen standards page points to general-industry standards for asbestos, the 13 carcinogens, benzene, formaldehyde and other carcinogenic exposures.

The "13 carcinogens" are one of those standards, 1910.1003: 4-nitrobiphenyl, alpha-naphthylamine, methyl chloromethyl ether, 3,3'-dichlorobenzidine and its salts, bis-chloromethyl ether, beta-naphthylamine, benzidine, 4-aminodiphenyl, ethyleneimine, beta-propiolactone, 2-acetylaminofluorene, 4-dimethylaminoazobenzene and N-nitrosodimethylamine. A mixture falls outside that standard below 0.1% or 1.0%, depending on the substance.

HazCom carcinogens go further than the 13. Where OSHA has identified cancer as a hazard for a chemical covered by Subpart Z, Appendix A requires manufacturers, importers and employers to classify it as a carcinogen. Classifiers may also use the latest NTP Report on Carcinogens and the IARC Monographs. For mixtures, Appendix A uses 0.1% for Category 1A and 1B, and 1.0% for Category 2.

PSM highly hazardous chemicals

1910.119 Appendix A lists highly hazardous toxic and reactive chemicals that "present a potential for a catastrophic event at or above the threshold quantity." Acrolein's threshold is 150 lb. Acetaldehyde is listed at 2,500 lb.

Particularly hazardous substances in labs

The laboratory standard, 1910.1450, uses a narrower hazardous chemical definition than HazCom: a health hazard or a simple asphyxiant. Particularly hazardous substances "include 'select carcinogens,' reproductive toxins and substances which have a high degree of acute toxicity." The chemical hygiene plan must consider extra provisions for them, including a designated area, a fume hood or glove box, waste removal and decontamination.

Your own hazardous chemical inventory list

HazCom does require one list, and the employer writes it. 1910.1200(e)(1)(i) says the written program must include "A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet." The list may cover the whole workplace or individual work areas.

The May 2024 update aligns HazCom mainly with GHS Revision 7. A 15 January 2026 extension moved every compliance date four months later. For substances, manufacturers, importers and distributors had a compliance date of 19 May 2026. For mixtures, their date is 19 November 2027.

Employers have later dates. For substances, they must, as necessary, update labels, the written program and training for newly identified hazards by 20 November 2026. For mixtures, the employer date is 19 May 2028. Until the date that applies to you, you may still comply with the pre-2024 version of the standard, the 2024 version, or both.

Hazardous materials and Tier II are not OSHA lists

OSHA does not keep a hazardous materials list. HazCom's term is hazardous chemical. The DOT Hazardous Materials Table "designates the materials listed therein as hazardous materials" for transportation.

EPCRA sections 311 and 312 apply to facilities that must keep SDSs under OSHA, but the inventory thresholds are EPA's. Hazardous chemicals are reportable at 10,000 lb. Extremely hazardous substances are reportable at 500 lb or the threshold planning quantity, whichever is lower. A 22 June 2026 EPA rule aligns those reports with the 2024 HazCom categories from 1 January 2028.

To see which of these lists name a given substance, ask RegAffairs AI, which answers from the OSHA tables and standards with cited sources.